But here is why it will only SICKEN YOU MORE, when ZD is walkin' around with $1.3 million, instead. Or even, $800K, PLUS THE COST OF ATTORNEY FEES...MINE AND YOURS! (And the city attorney department is already spread way too thin, and probably can't even prepare for summary judgment arguments, let alone new wave of lawsuits by DOWD/DOGG -- including our refusal to "sign off" on new Venice Beach system to assign spaces to people along the boardwalk. (ANY PARKS AND RECREATION STAFFER WHO PARTICIPATES IN THE NEW SYSTEM, BEING DISCUSSED IN TASK FORCE MEETINGS, WILL BE PERSONALLY NAMED IN THE NEW LAWSUIT RELATING TO THIS SYSTEM.)
SO NOW, ZUMA DOGG WILL TRY TO GET IT THROUGH THE DUMB HEAD OF STUPID, STUBBORN, HOSTILE, NEGLIGENTLY ARROGANT & VINDICTIVE LOS ANGELES CITY HALL:
# Listen to the audio of 9th Circuit Court of Appeals on Michael Hunt's case. THE CITY WAS TORN A "NEW ONE!" It is SHEER JOY AND COMEDY TO HUNT/DOWD/DOGG...and SHEER TRAGEDY for L.A. City Hall.- AUDIO: http://ow.ly/3R2sL
# THEN, keep in mind, that Hunt/Dowd's case was about confusing stuff like shea butter and incense; with debate about religious expressions and a lot of dicey, gray area. (And when you listen to the audio, it's CLEAR City got CREAMED!)
# Zuma Dogg's case, who is now a part of the case being discussed (as applied for damages), is a 1000%, CRYSTAL CLEAR, SHEER 1st AMENDMENT situation. NOTHING questionable or debatable or refutable on the city's part. Zuma Dogg shirts, cds, dvds, and free speech (singing/speaking) IS NOT UP FOR DEBATE. AND A ONE TIME VIOLATION OF 1st AMENDMENT RIGHT CONSTITUTES IRREPARABLE DAMAGES AS RECOGNIZED BY FEDERAL JUDGE.
# The City is desperate to try and bring some kind of system to the boardwalk in it's hope/attempt to assign spaces to people along the boardwalk. ZUMA DOGG & MATT DOWD WILL NOT SIGN OFF ON THIS -- AND DOWD, AS THE DESIGNER OF THE ALLEGED PROPOSED SYSTEM (as being mentioned at task force/neighborhood meetings) -- WE KNOW HOW TO ARGUE AGAINST IT, IN COURT!
# FORGET ABOUT ANY AND ALL DAMAGE AMOUNTS ZUMA DOGG MAY BE LOOKING AT, DOWN THE LINE, FOR FIVE YEARS OF 1st AMENDMENT VIOLATIONS AT VENICE BEACH, AND EVEN MORE IMPORTANTLY (at least to Zuma Dogg) -- FIVE YEARS OF "CODE OF CONDUCT" VIOLATIONS..."AS APPLIED" (which the city will LOSE!)...DAMAGES DISCUSSED SO FAR, ARE ONLY BASED ON VENICE BEACH...
#...The City Attorney's Office is stretched pretty thin, as it is. Can they really afford the staff and resources to prepare and argument that will become a "Code of Conduct" LOSING SUMMARY JUDGMENT. (Losing for the city, Winning for DOWD/DOGG.) A lot of money to spend, just cause you are treating ZD like a CHUMP with CHUMP CHANGE...WHEN IT WILL COST YOU MORE FOR ZUMA DOGG, ANYWAY...MY ADDED ATTORNEY WILL COST YOU A HELL OF A LOT MORE...YOU WILL HAVE TO SPEND CITY ATTORNEY RESOURCES ON SUMMARY JUDGEMENT...
#...AND: DOWD/DOGG have new follow-up lawsuits regarding constitutional violations at Venice Beach, and it will include challenging the sunset rules and 9am set up rules (based on new comments by California Coastal Commission on curfews that block access to State beach, without violating any laws).
#...The NEW lawsuit will challenge commercial vending and will be filed with proper standing and includes a bunch of new people.
# CITY COUNCIL NEEDS TO READ THE TRANSCRIPT OF MINUTES FROM HON. JUDGE DEAN D. PREGERSON'S COURT ROOM REGARDING DOWD/DOGG, et al vs City of Los Angeles from November 09, 2010. (DOWD/DOGG were in the room that day. We remember EVERY WORD. But don't have a copy of the transcript. City Council can easily acquire a copy. YOU REALLY, REALLY, REALLY, REALLY, REALLY NEED TO READ IT BEFORE YOU FLIPPANTLY DECIDE ZUMA DOGG ISN'T WORTH $400K TO GET RID OF. (So drop the low-ball arbitrary and capricious numbers. They are arbitrary and capricious.)
SUMMARY: Although DOWD/DOGG/ROSENDAHL/CITY ATTORNEY is fully aware of the negative financial impact the City of Los Angeles is looking at when you add up damages amount ZD is looking at down the line; added cost of high-priced attorney who will crush you even more than DOWD/DOGG have been; cost of not being able to move forward with new plans at Venice Beach; losing Code of Conduct "as applied" (and maybe ZD argues it facially, in whole as unconstitutional, but even "as applied" would be crushing and profoundly more expensive, as it is; AND THE FACT THAT THE CITY ATTORNEY'S OFFICE AND THE REST OF CITY HALL (LAPD, PARK & RECS, COUNCIL OFFICES) SHOULDN'T BE SPENDING SO MUCH TIME, MONEY & MANPOWER -- ONLY CAUSE THEY HAVE A PERSONAL PROBLEM WITH HAVING ZD WALK AROUND WITH $400K IN HIS POCKET...
IT WILL COST THEM PROFOUNDLY MORE IN ADDED EXPENDITURES -- AND IT WILL BE MUCH MORE PUBLIC JUST WHEN IT'S MUCH MORE EXPENSIVE.
Any prudent fiscalist would say, "Damn, that ZD sure does care about the city with his overly-compassionate low-ball amount he's willing to accept for such GIANT MUNICIPAL ISSUES revolving around a FEDERAL DEFEAT, with MORE FEDERAL DEFEAT TO COME. What a nice guy!"